Introduction

Wells Independents (“WIN”) respect individuals’ rights over their personal data. We are committed to ensuring that people are treated fairly in everything we do.

Where this Notice refers to ‘personal data’ it is referring to data about you (or other living people) from which you (or they) could be identified – such as name, date of birth or contact details.

This Notice applies to all personal data processed by WIN about its supporters and members of the public. This includes data gathered via third parties, such as social media sites, and which is therefore also covered by their own Privacy Policies.

This policy was last updated on 5th March 2019. Any updates will be posted to this version of the policy. If you wish to see a previous version of the policy, or have any other questions, please get in touch.

WIN may collect personal data from you via means such as:

  • In person, when you speak to one of our representatives or volunteers
  • Through a telephone call, either where you call us or we call you
  • On paper, such as if you return a printed survey or a reply slip on a leaflet
  • Digitally, such as if you fill in a form on a website or interact with WIN online
  • When you offer or ask about volunteering, or take part in party activities
  • When you enter into a transaction with WIN, such as donating, joining, purchasing a product or paying for an event
  • Indirectly from other public records or sources, including the full electoral register which WIN is legally entitled to
  • On social media platforms, where you have made the information public, or you have made the information available in a social media forum run by WIN

We may collect personal data about you such as:

  • Name
  • Contact details (e.g. email address, address, telephone / mobile number)
  • Date of birth
  • Future communication preferences
  • Information about your financial transactions with WIN
  • Family details
  • Political opinions
  • Religious or other beliefs
  • Other demographic information
  • Information about your home (e.g. whether it is a flat or house)
  • Issues you raise
  • Topics you are interested in

We may also collect information when you interact with WIN digitally, such as by visiting one of our websites or communicating with one of our social media channels.

We may also collect information about you from other public sources, such as the Land Registry, Companies House or other commercially available sources. We only do so where those sources are lawfully permitted to share the data with us and where we have a legal basis to process data from such sources. This may include, for example, checking the eligibility of a potential donor and may include additional data to that above, such as:

  • Lifestyle and social circumstance
  • Goods or services purchased
  • Charities you support

How we may use your personal data

We may use your personal data to further our objectives, share it with our elected representatives and/or contact you in future. Examples of the way we may use your data include to:

  • Contact you to canvass for political support
  • Understand your views and issues important to you
  • Process surveys you have participated in
  • Tell you about policies, campaigns or individuals that may be of interest to you
  • Respond to queries that you raise with us
  • Administer offers or applications to volunteer for WIN or to become, remain or cease being a member of or candidate for WIN
  • Conduct fundraising activities, including checking your eligibility to donate
  • Manage our sites and services

For more specific information about how we use your data for these activities, and the legal basis on which we rely to process your data in this way, please see the ‘Why WIN is allowed to use your information in this way’ part of this Notice.

If you have provided us with your email, mobile phone number or landline phone number and we have a legal right to use them for such purposes, we may use that information to contact you to promote causes and campaigns that we support, such as by sending you an email, online advert, or a text message.

We will respect any registration you hold with the Telephone Preference Service (TPS) except where you have opted in to receive phone calls on that number from us.

  • Please note: you may opt out of communications from us at any time.

Depending on how and why you provide us with your personal data it may be shared within WIN or with companies that provide services to WIN (“service providers”).

In addition, we may share your personal data with third parties when we are required to do so by law (for example, with the Police where they ask us to assist them with their investigations).

However, save for the limited circumstances noted above, we will never pass your personal data to any unrelated third parties unless you have given us your permission to do so. For example, where you have signed a petition and are clearly informed that this petition will be presented to a third party.

Why WIN is allowed to use your information in this way

WIN is a registered minor political party in the city of Wells; our work is designed to promote our values and to engage Wells citizens in the democratic process.

Accordingly, our work is considered to be of substantial public interest. Because of that public interest basis, we are entitled to process personal data which relates to your opinions, and your personal data more generally, for the purposes of enabling us to perform our work effectively. Specifically, that processing may include using those aspects of your personal data to help us to plan and execute campaigns, canvass for your support (such as by visiting or calling you), raise funds, and perform casework that relates to you and your local community.

You do have rights to ask us to stop processing your data for these purposes, and you can read details about those rights here. In addition to the above we may also process your data for other purposes where you ask us to or enter into a relationship with us that requires us to.

For example, if you choose to join us as a volunteer, we will need to process your personal data to record that you have given us your support in this way. A contract will be put in place between you and us and we will process your personal data to the extent that we need to in order to fulfil our obligations under that contract.

Similarly, you may from time to time give us your consent to send you communications by e-mail (or similar mediums) which promote our work. Where you do that, we will use your details to send you those kinds of communications until you tell us otherwise. Should you ever ask us to stop sending those kinds of communications we will hold your details on file to ensure that we respect that request – we justify that retention on the basis that we have a legitimate interest in holding your data in that way.

Finally, where we have received your personal data in the various ways described above, we may continue to hold it as part of our records after the relevant processing has stopped. We hold data in this way because we have a legitimate interest in doing so. Specifically, where you have been a supporter or a volunteer (or have otherwise engaged with us such as by attending a meeting or event, or by responding to a survey or questionnaire) we have a legitimate interest in holding your personal data to help us to monitor the numbers and the diversity of people who engage with us, as well as a legitimate interest in making sure that we can follow up any complaints or grievances which you may raise (or which people may raise about you).

The circumstances under which we may share your personal data or disclose it to others

WIN will not sell your personal data to third parties.

Depending on how and why you provide us with your personal data, it may be shared within WIN and our elected representatives. It may also be shared with those who provide services to WIN (“service providers”).

We may use service providers to undertake processing operations on our behalf to provide us with a variety of administrative, statistical, advertising and technical services. We will only supply service providers with the minimum amount of personal data they need to fulfil the services we request. We oblige all of our data processors to sign contracts with us that clearly set out their commitment to respecting individual rights, protecting your personal data – including not using it for any purpose other than providing us with an agreed service or fulfilling their legal obligations – and their commitments to assisting us to help you exercise your rights as a data subject.

With your consent, service providers may hold personal data about you in order to facilitate the provision of future services or financial transactions to which you have agreed, such as a payment processor retaining your payment details in order to process agreed future payments from you.

In addition, we may share your personal data with third parties when we are required to do so by law (for example, with the Police where they ask us to assist them with their investigations). In some cases, this may result in your personal data becoming public.

In particular, WIN and our candidates are required to submit records, including personal data, of donations above certain thresholds to the relevant regulatory authority. In some cases, some of these donation details are made public. For more details about this, please contact us.

However, save for the limited circumstances noted above, we will never pass your personal data to any unrelated third parties unless you have given us your permission to do so.